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Interim Guidance for Protecting Deepwater Horizon Response Workers and Volunteers

NOTE: This page is archived for historical purposes and is no longer being maintained or updated.

I. General Recommendations

The National Institute for Occupational Safety and Health (NIOSH) and the Occupational Safety and Health Administration (OSHA) recognize that many important and well-considered efforts to protect the health and safety of Deepwater Horizon Response workers and volunteers are currently being implemented.  To ensure a comprehensive approach to safety and health, NIOSH and OSHA recommend that:

  1. Exposures to toxic chemical and physical agents, heat, fatigue and psychological stress should be reduced by using engineering and administrative controls (including work-rest cycles, distance, location and barrier protection) and, where necessary, the use of personal protective equipment (PPE);
  2. Exposures to toxic chemical and physical agents should be comprehensively and routinely assessed during work activities under varying conditions. Validated methods for area and personal breathing zone sampling should follow an approved, standardized and comprehensive Deepwater Horizon Response air sampling plan coordinated among all relevant  government agencies and non-governmental organizations (and their contractors) that are conducting sampling activities;
  3. Dermal exposures to crude oil and toxic chemical agents should be minimized for response activities in which the chance for dermal exposure is high and appropriate PPE should be worn;
  4. Selection and use of PPE, including the full protective ensemble, should consider and address the potential to increase heat stress problems in workers and volunteers;
  5. All workers and volunteers should be educated about hazards associated with response activities1, encouraged to participate in worker and volunteer rostering2, and have a pre-placement medical evaluation;
  6. All health symptoms, illnesses, injuries or near-misses related to work activities should be reported by workers and volunteers; should be recorded by employers, contractors and volunteer organizations; and should be evaluated by safety and health or licensed health care professionals with action taken to protect workers;
  7. Periodic, systematic reviews and evaluation of health symptoms, illnesses, injuries or near-misses related to work activities should be done and preventive action taken; and
  8. Workers and volunteers should be provided training and assistance to prevent psychological stress associated with response activities and to support resiliency. 3, 4

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II. Health Effects from Crude Oil and Oil Dispersant Exposure

Crude oil is a complex mixture of chemical constituents including various alkanes (butane, pentane, and hexane), aromatic hydrocarbons (benzene, ethyl benzene, toluene, and xylenes), cycloalkanes, other nitrogen, oxygen, and sulfur compounds (hydrogen sulfide) and trace metals such as iron, nickel, copper and vanadium. Some constituents of crude oil can have significant toxicity. For example, several aromatic hydrocarbons are considered to be human carcinogens.5 The International Agency for Research on Cancer (IARC) indicates that for crude oil, there is inadequate evidence for the carcinogenicity in humans, although there is limited evidence for carcinogenicity in experimental animals.6

Hydrocarbon exposure from crude oil constituents will vary based on its exposure to the atmosphere, time in the marine aquatic and coastal environment, treatments with dispersants and interaction of the chemicals, wave action and heat. Generally, the more "aged" or "weathered" crude oil is (by mixing with seawater and traveling long distances from the source), the lower are the concentrations of volatile organic compounds (VOCs). Although it generates less VOCs, weathered crude oil still contains harmful chemicals which can cause skin irritation and other irritant reactions. Thus, use of gloves and protective clothing is recommended to minimize skin contact with weathered oil, including oil deposited on the shore (“tarballs” or “tarpatties”). Appropriate hand hygiene facilities should be readily available to clean incidental skin exposures.

Weathered crude oil is unlikely to pose an inhalation risk although a potential risk does exist for it to be aerosolized into respirable airborne droplets or volatilized by activities such as pressure washing. Even though detection of hydrocarbon "odors" is common in areas contaminated by crude oil, odor is not a reliable indication of a health hazard. Some individuals, though, are bothered by odors and can develop symptoms (e.g., may report dizziness, nose and throat irritation, headache and/or nausea). These individuals may need medical evaluation when symptoms occur, especially if severe or persistent. Individuals with severe or persistent symptoms should be relocated to perform tasks where symptoms can be alleviated.

Studies of tanker oil spill responses have reported adverse health effects in response workers. 7, 8,9,10,11,12,13,14,15 A summary of studies about the human health effects associated with selected oil tanker disasters can be found in Appendix A. These studies may underestimate the health effects associated with the Deepwater Horizon Response activities since the magnitude and duration of the Response is unprecedented. In addition, there is an incomplete understanding about the human health toxicity associated with the use of large amounts of dispersant, about the toxicity of the mixed exposure to large amounts of crude oil, dispersants and combustion products together and the cumulative effect of such exposures occurring over a long duration.

Since knowledge about potential inhalational exposures to the mixed exposure of crude oil, dispersant and combustion products associated with the Deepwater Horizon Response work is incomplete and still evolving, NIOSH and OSHA believe it is prudent to reduce the potential for adverse health effects by the responsible use of engineering controls, administrative controls and PPE, including respirators when appropriate. In the absence of comprehensive and coordinated health surveillance among workers and volunteers, and the absence of interpretable, quantitative exposure data, NIOSH and OSHA recommend that employers take precautions sufficient to ensure workers are protected from the chemical, physical and psychological hazards posed by the Deepwater Horizon Response.

Note 1: OSHA is currently monitoring worker exposures and looking for levels of airborne exposure shown likely to cause health effects from chemical exposure to fresh crude oil, weathered oil, dispersants, cleaning agents and other materials. Current OSHA monitoring results can be found at http://www.osha.gov/oilspills/oil_directreading_bysite.html. To date, no air sampling by OSHA has detected any hazardous chemical levels of concern.

Note 2: At the request of BP, NIOSH is conducting health hazard evaluations (HHEs) to evaluate worker exposures and health effects from the fresh crude oil, weathered oil, dispersants, cleaning agents, and other chemicals (e.g., diesel emissions) across all response activities. NIOSH is posting updates about HHE activities on the NIOSH website at http://www.cdc.gov/niosh/hhe/ .

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III. Conducting Exposure Assessment

At this time, there is a need for a coordinated, comprehensive and routine air sampling plan for all response worksites among those government agencies and non-governmental organizations (and their contractors) that are conducting sampling activities. A comprehensive exposure assessment of the Deepwater Horizon Response work activities involves evaluation of multiple different work settings, each with its own set of exposure variables. These work settings involve changing weather conditions, various types and amounts of VOCs being released, work tasks resulting in potential skin and inhalational exposures, and exposure to wildlife and physical hazards, such as heat, snakes and insects. In addition, response workers and volunteers are engaging in activities that may be unfamiliar, thus increasing the potential for injury or exposure.

Exposure assessment to hydrocarbons using traditional 8-hour, 40-hour per week, shifts should be adjusted to reflect the greater duration of work shift and work week exposure experienced by Deepwater Horizon Response workers. Most existing occupational exposure limits for determining harmful levels of chemical agents are based on an 8-10 hour workday and a 40-hour work week. 16 For extended hours, downward adjustment should be made to the exposure limit based on hours worked. Rote application of exposure criteria without adjustment will not provide sufficient protection to workers engaged in long-duration response work. Published methods are available to adjust exposure criteria for extended work shifts.17

Respiratory protection precautions are necessary for uncharacterized chemical exposures until the need for such precautions has been ruled out by comprehensive assessment of exposures to toxic chemical agents during work activities under a variety of relevant conditions. Quantitative methods for area and personal breathing zone sampling should follow an approved, standardized and representative Deepwater Horizon Response air sampling plan coordinated among all government agencies and non-governmental organizations (and their contractors) which are conducting sampling activities. Routine, ongoing exposure assessment should continue as part of a comprehensive worker safety and health program.

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IV. Pre-Placement Medical Evaluation

NIOSH is developing recommendations for pre-placement medical evaluations for workers involved in the Deepwater Horizon Response.   These recommendations are designed to: (1) provide health care professionals with guidance on the important elements  of a pre-placement evaluation;  (2) assist health care professionals in identifying (a) workers with health concerns that need to be addressed, (b) workers that may have specific susceptibilities for whom activities may need to be restricted or modified, and (c) workers with medication, immunization or training needs; and (3) provide valuable information to the worker on his/her health status and the potential demands of the work they are undertaking. However, NIOSH recommendations are not intended to replace existing medical evaluation programs.

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V. Medical Care and Symptom, Near-Miss, Injury and Illness Reporting and Recording

Workers are urged to report any symptoms they associate with their response work to their employer, their physician, state or local health department or a local health facility.  Symptoms reported from excessive exposure to crude oil/dispersants commonly include eye, nose and throat irritation, headache, dizziness, upset stomach, cough or shortness of breath.

Workers are urged to seek medical attention for any symptoms they associate with their response work. Workers should also have immediate access to medical care provided by licensed healthcare professionals with appropriate expertise.  All medical conditions should be assessed for work-relatedness of the illness or injury. 

Workers should be encouraged to report any occurance of symptoms, near-misses, injuries and illnesses. These reports should be analyzed to assess real-time trends so that actions can be taken to prevent similar incidents.  This information is also useful in identifying the potential for long-term health effects.  Symptom, near-miss, illness and injury data should be readily available to all partners, including state and local health officials, as well as the general public.

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VI. Heat Stress Prevention

Deepwater Horizon Response workers and volunteers are at very serious risk for developing heat stress.  Many heat stress programs already have been implemented in the Deepwater Horizon Response. The following discussion is meant to review the basic elements of a heat stress program. Excessive exposure to hot environments can cause a variety of heat-related problems, including heat stroke, heat exhaustion, heat cramps, and fainting. Heat can also increase the risk of injuries in workers from sweaty palms, fogged-up safety eyewear, and dizziness. Protective clothing and other PPE will increase the risk of heat-related problems. PPE should be selected to minimize heat stress on the wearer.

Workers at greater risk of heat stress include those who are 65 years of age or older, are overweight, have heart disease or high blood pressure, or take medications that may be affected by extreme heat. Heat stroke is the most serious heat-related disorder and occurs when the body becomes unable to control its temperature; the body's temperature rises rapidly, the sweating mechanism fails, and the body is unable to cool down. Heat stroke can cause death or permanent disability if emergency treatment is not given.

Note that requiring or allowing workers to use certain types of PPE, particularly dermal PPE, that is not required for their specific work task, will increase the potential for the development of heat stress.

Prevention of heat stress in workers is important. A heat stress program should include the following elements:
 

  • Information for workers about the effects of heat stress, and how to recognize heat-related illness symptoms and prevent heat-induced illness;
  • Acclimatization of new workers or workers returning to work from absences of three or more days 18   
  • Specific procedures to be followed for heat-related emergency situations;
  • Provisions to administer first aid immediately to workers displaying symptoms of heat-related illness. 

Additional elements include the following:

  • Addressing and reducing physical demands on workers;
  • Using relief workers or assigning extra workers for physically demanding jobs;
  • Providing cool water to workers—avoiding drinks with caffeine, alcohol, or large amounts of sugar;
  • Establishing specific work-rest regimens based on the physical demands and environmental heat-related conditions;
  • Scheduling work cycles to coincide with cooler temperatures in the day or night;
  • Providing cool and shady areas for use during rest breaks; and
  • Monitoring workers through a buddy system for signs of heat stress.

Several resources about preventing heat stress are available at the following websites:

NIOSH (http://www.cdc.gov/niosh/topics/heatstress/)
OSHA (http://www.osha.gov/SLTC/heatstress/index.html)
Cal/OSHA (http://www.dir.ca.gov/dosh/healthillnessinfo.html)

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VII. Fatigue Prevention


 

Disaster response workers often work longer shifts and more consecutive shifts than the typical 40-hour work week.  Working longer hours may increase the risk of work injuries and accidents and can contribute to poor health. The scientific literature indicates that working at least 12 hours per day was associated with a 37% increased risk of injury19 and construction workers working more than 8 hours per day had a 15 % higher injury rate.20 Fatigue and stress from strenuous work schedules can be compounded by heavy physical workloads, unfavorable environmental conditions (e.g., damaged infrastructure, hazardous materials and debris, sparse living conditions), long commutes, and personal demands on workers.

Therefore, disaster response organizations should have management plans in place to minimize fatigue risks, recognize hazards, and provide regular opportunities for worker rest and recovery. The National Response Team, an organization of 15 Federal departments and agencies responsible for coordinating emergency preparedness and disaster response, has prepared guidance and checklists for managing fatigue during disaster recovery operations.
Consider the following general guidelines: 21,22,23,24

  • Regular Rest:  Establish at least 10 consecutive hours per day of protected time off-duty in order to obtain 7-8 hours of sleep.  Rest and a full complement of daily recovery sleep are the best protections against excessive fatigue in sustained operations.  Allowing only shorter off-duty periods (e.g. 4-5 hours) can compound the fatigue of long work hours.
  • Rest Breaks Frequent brief rest breaks (e.g., every 1-2 hours) during demanding work are more effective against fatigue than few longer breaks. Allow longer breaks for meals.
  • Shift Lengths Five 8-hour shifts or four 10-hour shifts per week are usually tolerable.  Depending on the workload, twelve-hour days may be tolerable with more frequent interspersed rest days. Shorter shifts (e.g. 8 hours), during the evening and night, are better tolerated than longer shifts. Fatigue is intensified by night work because of nighttime drowsiness and inadequate daytime sleep.
  • Workload Examine work demands with respect to shift length.  Twelve-hour shifts are more tolerable for “lighter” tasks (e.g., desk work).  Shorter work shifts help counteract fatigue from highly cognitive or emotionally intense work, physical exertion, extreme environments, or exposure to other health or safety hazards.
  • Rest Days Plan one or two full days of rest to follow five consecutive 8-hour shifts or four 10-hour shifts. Consider two rest days after three consecutive 12-hour shifts.

For additional information on working hours, see www.cdc.gov/niosh/topics/workschedules.

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VIII. Traumatic Incident Stress Prevention

Workers and volunteers may experience stress and fatigue when they respond to environmental disasters, both natural and human-caused. Deepwater Horizon response workers and volunteers are at risk of feeling uncomfortable levels of stress from what mental health professionals refer to as a traumatic incident. The term traumatic is used because of an unexpected and troubling change in the natural order of things, such as the untimely death or injury of oil-covered wildlife and the impact on fishing communities and the environment. It is important that responders monitor their health and well-being during their response activity period, and even months after their response work has ended.

Specific recommendations to help manage responder stress and fatigue during and after a response (in addition to tips for parents, teachers, and response workers) can be found on the Substance Abuse & Mental Health Services Administration (SAMSHA) website at http://samhsa.gov/Disaster/ and the NIOSH website at http://www.cdc.gov/niosh/topics/oilspillresponse/traumatic.html.

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IX. Use of Personal Protective Equipment

A variety of PPE will be needed by Deepwater Horizon Response workers and volunteers. Administrative controls and engineering controls should be utilized first to minimize the need for PPE in any particular job.  Where such controls will not effectively minimize the exposures, then PPE will be necessary. Appropriate selection of PPE begins with answering two questions: (1) what are the hazards faced by a worker or volunteer in a particular job? (2) what is the anticipated level of hazard exposure for a worker or volunteer in doing that job? 

Crude oil and its constituents, as well as oil dispersants, can cause skin irritation and inflammation.  NIOSH and OSHA recommend avoiding all unprotected skin and eye contact to crude oil, dispersants and other chemicals used during response activities.  PPE to prevent skin contact must be selected carefully for use in a hot, wet environment.  Skin damage due to chaffing from increased sweating, coupled with the mechanical stress of ill-fitting PPE, can compromise the skin’s natural barrier against bacteria.  In addition, the use of sunscreen, shaded safety glasses and wide-brimmed hats are recommended.

For many response tasks, gloves, protective clothing and protective footwear will be necessary. Several types of materials are capable of protecting against crude oil, including those made from neoprene, nitrile and butyl rubber, as well as other commercially available products. PPE should be evaluated before purchase and use by contacting the manufacturer to be sure it has barrier performance against the expected exposures.   For eye/face protection, safety glasses, safety goggles, or face shields may be required depending on the specific work activity.

A good source for information about eye and face protection, protective clothing, gloves and protective footwear can be found at http://www.osha.gov/oilspills/oil_ppematrix.html.25

A. Guidance on Selection of Protective Clothing

Choosing the proper chemical and flame resistant protective garments is an exercise in the selection of fabric, seam and design. The selection must be based on expected exposure and verified by field audits and changed if the selected PPE does not perform adequately. The potential for contribution to heat stress must also be considered in the selection of protective clothing, in addition to the potential exposure to fire, water, oil and tar, and other chemicals. In general, overprotection from chemical and fire exposure generally creates a greater potential for heat stress. Partial body garments such as aprons and sleeves may be used to help reduce the risk of increased heat stress where the potential for heavy exposures to certain parts of the body is limited and hygiene facilities to handle incidental exposures exist. Evaluate the job to determine where it is feasible to use lower levels of PPE to reduce potential heat stress.

1. Selection of Fabric

When exposures may require repulsion of droplets of oil., repellant-treated fabrics should be used. Some treated fabrics will become oil soaked when subjected to higher quantities of liquid oil under pressure. Coated fabrics generally offer a higher level of barrier to liquid oil and are divided into two categories – impermeable and selectively permeable barrier materials or fabrics. Both types will provide a physical barrier to liquid and solidified oil. These fabrics come in a range of weights and durability. Full body garments made from impervious film fabrics have higher potential for heat stress. Microporous film fabrics often use thin films to achieve high moisture transport. These products may be easily abraded and damaged, thus compromising the barrier protection of the fabric. Uncoated or permeable fabrics, spun-bonded polypropylene and polypropylene SMS (spunbond/meltblown/spunbond), will, in general, absorb or allow penetration of oil but typically result in lower heat stress for the wearer. Garments made with permeable fabrics should be considered in situations where little or no liquid oil contact is expected, such as removing tar balls from the beach. Partial body garments, such as sleeves and aprons worn over these garments, can provide added barrier protection in areas of the body where greater exposure is expected or observed. Partial body garments can be made from the same impermeable fabrics or from impervious film fabrics. Flame resistant clothing should be selected in accordance with 29 Code of Federal Regulations (CFR) Section 1910.132, the General Industry Standard for PPE.

2. Selection of Seams

Taped and welded seams are appropriate when the seams will come into contact with liquid chemicals under pressure or when there is sufficient liquid to form pools, puddles or run-off on the garment. Garments made from impervious film fabrics should have welded or taped seams to prevent liquids from entering through the seams when significant contact with liquids is expected. Sewn, serged or bound seams without sealing tape should only be considered in situations which involve minimum liquid volumes and minimum contact pressure. Sewn, serged or bound seams are normally found on most garments made from uncoated fabrics, microporous film fabrics, and some garment made with lightweight impervious film fabrics.

3. Selection of Design

The most common form of chemical and flame resistant clothing is the coverall. However, full body protection can also be obtained with the combination of jacket and bib overalls, or a shirt and pants combination. The protection provided by the garment closure and interface areas between garments should be considered when selecting PPE. Closures and interface areas (i.e., glove to jacket) provide a potential point of entry for hazards. If significant liquid contact is expected, the closure and interface areas should be minimized and provide the same level of protection as the rest of the garment. If less than full body protection is acceptable, partial body garments present a significantly lower heat stress impact than full body coveralls. There are many job activities associated with this response where the worker will have localized exposure to contaminated materials or fire. Partial body garments, such as sleeves, aprons, pants and shirts, can help protect those parts of the body that will be potentially exposed, such as forearms, front of the body or legs.

Note: Workers should remove gloves, and any other PPE that could contaminate food or drink, and thoroughly wash their hands with soap and water before eating. Workers should also remove all PPE before leaving the contaminated area at the end of the shift to reduce take-home exposure.

B. Reuse of Personal Protective Equipment

Consult the manufacturer’s instructions on whether personal protective equipment should be disposed of or cleaned after use. If it can be cleaned, consider whether any special procedures are required for disposing the decontaminated waste. Tears, rips, pinholes, and other damage can result in penetration of the crude oil or other contaminants through the PPE. When damage is present, the PPE generally will need to be replaced since repair is often impractical.

1. Protective Clothing and Gloves

All chemicals including crude oil can be expected to permeate through protective barriers sooner or later. Permeation can take place without visible evidence in the protective materials. Many manufacturers of PPE, in particular manufacturers of gloves, will provide information on breakthrough times from various chemicals (time it takes for the chemical to pass through the protective material). The PPE will need to be removed and discarded prior to the stated breakthrough time. Users should consult with the specific manufacturer to confirm the performance of their product.

2. Respirators

Given the warm and humid conditions existing during the Deepwater Horizon Response, disposable filtering facepiece respirators will likely need to be discarded after several hours of use, in part because they will become moist with perspiration. These respirators should be discarded and replaced if they are soaked, contaminated, damaged, or hard to breathe through. For intermittent use of disposable filtering facepiece respirators, they may be stored in a clean, breathable container, such as a paper bag between uses. Disposable filtering facepiece respirators must be used only by a single wearer. Elastomeric respirators can be cleaned, disinfected and reused. Specific information on cleaning re-usable respirators can be found in the OSHA Respiratory Protection Standard.26

C. Use of Respiratory Protection

A decision to use respiratory protection should be based on the best available qualitative information using the expert opinion method and on the best available comprehensive quantitative information about the type and level of exposure to toxic chemical and physical agents by the inhalational route. The use of effective engineering and administrative controls, and other personal protective equipment should be implemented before the use of respirators for worker protection is considered.

1. Source Control Activities

The source control vessels conduct activities closest to the area where crude oil appears on the surface, including drilling relief wells, conducting underwater operations at the source including dispersant application, and providing support and supplies. If surface application of dispersant is deemed necessary, it should be applied at a safe distance from vessels operating in the area. Variable concentrations of hydrocarbons are likely present in the air in and around these vessels. Engineering and administrative controls should be used to control hydrocarbon vapor levels during source control activities, but exposures to crude oil-derived VOCs and other constituents may not be eliminated entirely. Significant spikes in concentrations may occur unexpectedly, and would necessitate donning a respirator especially when engineering and administrative controls cannot provide protection.

For workers involved in source control activities, respirators should be used in those situations where potentially excessive exposure is reasonably anticipated or where indicated by exposure assessment or where symptoms/health effects are being reported. Where eye protection is not needed against irritating gases/vapors, NIOSH and OSHA recommend using a half facepiece respirator. If eye protection is needed, NIOSH and OSHA recommend a full facepiece elastomeric respirator with an organic vapor/P100 cartridge. A full facepiece respirator provides eye protection against irritating gases/vapors and a relatively high level of respiratory protection when exposures are variable and potentially higher. Cartridges including P100 particulate filters (oil resistant) are recommended over N95 filters (not resistant to oil aerosols). The combination organic vapor/P100 cartridge provides comprehensive protection against both particulates and gases and vapors, and the P100 filter provides some protection against water mist for the organic vapor filter component.

2. Off-Shore Activities

a. Vessels Involved in Burning Crude Oil

Vessels involved in crude oil burning are exposed to crude oil/dispersant that is less aged and may emit more VOCs than crude/dispersant closer to shore that may have undergone more weathering. The primary hazards from in-situ burns are likely to be heat, exposure to products of combustion and, rarely, flash fire. Some vessels engaged in burning may be working in close proximity to source control activities.

Products of combustion will include a complex mixture of particulate matter, smoke and soot; VOCs such as partially oxidized alcohols, aldehydes, and ketones; metals like vanadium, chromium, and nickel; and gases such as carbon dioxide and carbon monoxide.27,28 The chemical composition of these emissions will vary based on the oil composition, weather conditions during each burn, and the completeness of the combustion process. When in-situ (i.e., on-site) burns are conducted, they should be conducted remotely with all vessels positioned upwind at an adequate distance away from the resultant smoke plume. Every effort should be made to keep workers from the area of the smoke plume, and to evacuate them as quickly as possible when changing conditions may put them in the area of the contaminants of the burn.

Under ideal conditions, vessels will be located a sufficient distance upwind from burns, and respiratory protection may not be necessary. The employer should assess the specific job tasks before the burning activity to evaluate potential worker exposures and then select respiratory protection and other PPE according to the results of their evaluation. Respiratory protection will be needed, however, when shifts in wind cause exposure to the combustion products in the plume. Under such circumstances, or where symptoms/health effects are being reported, inhalational exposure may occur and NIOSH and OSHA recommend respiratory and eye protection.

For unexpected exposures, protection can be provided by use of a full facepiece elastomeric respirator with an organic vapor/P100 cartridge. A full facepiece respirator is preferred because it provides both eye protection against irritating smoke and an appropriate level of respiratory protection. Cartridges including P100 particulate filters (oil resistant) are recommended over N95 filters (not resistant to oil aerosols). The combination organic vapor/P100 cartridge provides comprehensive protection against soot, gases and vapors. Another means of protection is non-vented safety goggles to prevent eye irritation and a half-mask respirator with an organic vapor/P100 cartridge.

Note: Flame resistant clothing will help protect workers, for instance, such as those workers in the igniter boat during in-situ burning. The clothing should be cleaned, maintained, and regularly inspected in accordance with the manufacturer’s instructions. Some flame resistant clothing may lose its protective qualities after repeated or improper cleanings. Wearing any flammable clothing over flame resistant clothing will negate the flame resistant protection. Flame resistant clothing should be selected in accordance with 29 CFR Subpart I (Personal Protective Equipment), Section 1910.132, General Requirements.

b. Vessels Not Involved in Source Control or Burning

Some vessels operating off-shore engage in deployment of containment and sorbent booms, skimming operations to remove oil from the water, and dispersant application. These vessels are not involved in burning nor are they located in close proximity to in-situ burning. Generally, these vessels have contact with oil that has weathered, and, as such, does not emit significant amounts of VOCs. Respiratory protection generally will not be necessary as symptoms/health effects are not expected to occur in this setting. Dermal protection is needed.

Other vessels not involved in burning may operate at a farther distance from shore and possibly encounter more volatile crude. In this case, administrative controls (e.g., worker rotation and decrease in work hours) and respiratory protection (e.g., half-mask elastomeric respirator with an organic vapor cartridge) should be implemented where symptoms/health effects are being reported.

Note: Representative and routine air and personal breathing zone monitoring should be conducted to verify that unsafe exposures are not occurring, especially when these vessels operate in areas where partially weathered crude oil exist.

3. Shoreline Clean-up Activities

The types of activities associated with shoreline cleaning include manual removal of “tarballs” or “tarpatties,” shovel removal of oiled-contaminated sand, low pressure flushing, manual sorbent application, and manual cutting of vegetation. Since inhalational exposure to oil and dispersants during shoreline clean-up operations is low because of weathering, respiratory protection is not recommended. However, if symptoms/health effects occur, the affected worker(s) should be removed and evaluated medically, and then the worksite should be assessed for potential exposure to heat and VOCs for the remaining workers.

Note: If high pressure washing is conducted, aerosolization of oil mist into respirable droplets could occur and respiratory protection is recommended with use of at least the level of a disposable P100 filtering facepiece respirator. The use of highly concentrated detergents, degreasers, and solvents, and the use of heated water during pressure washing, may volatilize hydrocarbons and result in the need for respiratory protection. Respiratory protection, if deemed necessary by professional judgment and/or air monitoring results, should include the use of a combination organic vapor/P100 cartridge half mask respirator. Eye and skin protection during such activities also will be necessary.

4. Decontamination Activities

<<h5> a. PPE and Other Equipment

Vessels, PPE and other equipment may become contaminated with weathered oil. Respiratory protection is generally not necessary for this activity, although other PPE, including dermal, eye, face protection and protective footwear is necessary. If a high pressure washing mechanical sprayer is used to decontaminate PPE and other equipment, respirable particle aerosolization of oil mist could occur. When there is potential exposure to oil mist, particulate respiratory protection of at least the level of a P100 disposable filtering facepiece respirator is recommended in addition to skin, eye, face protection and protection footwear, particularly if highly concentrated detergents, solvents or degreasers are used.

b. Cleaning Wildlife

Task observations of cleaning and caring for birds, turtles and other wildlife indicate that aerosols of water, crude oil, soap, ammonia and other chemicals are likely to be generated. Eye and face protection, in addition to skin protection is recommended. When irritating concentrations of ammonia are experienced, dilutional ventilation, for example, by means of fans and other means to increase air exchange, are recommended.
Recommended PPE includes eye protection, i.e., safety glasses, goggles or face shields. Birds will peck under stress and may aim for the eyes. Eye protection is also necessary to protect against large droplet sprays from struggling birds. Oil-resistant outer protective clothing is recommended. An oil-resistant gown may provide sufficient upper body protection, avoiding the need for coveralls. Gloves (neoprene or nitrile rubber) that are oil resistant and provide protection against pecking and sharp talons are recommended. Non-skid footwear or boots that are oil-resistant and waterproof are also recommended.29 Respiratory protection is not generally recommended, unless wildlife is heavily coated with fresh crude oil. In such cases, a half mask respirator with an organic vapor cartridge is recommended.

5. Waste Stream Management Activities

Response and remediation workers are engaged in the disposal and recycling of hazardous solid and liquid wastes during collection, storage, transport and final disposal. Deepwater Horizon Response waste management workers are at risk of a number of hazards including falls, other musculoskeletal injury, and dermal exposure to the components of the waste stream. Waste stream management workers should be trained, provided appropriate PPE, and have their work activities monitored for exposure in compliance with applicable state and Federal laws and regulations. 30

D. Resources for Use of Respiratory Protection

For authoritative information from a trusted source to verify which respirators are approved by NIOSH, how to get them and how to use them, see the NIOSH Respirator Trusted-Source Information Page at http://www.cdc.gov/niosh/npptl/topics/respirators/disp_part/RespSource.html#sect1. For more information on NIOSH-approved respirators, see http://www.cdc.gov/niosh/topics/respirators/. For information on chemical hazards, see the NIOSH Pocket Guide to Chemical Resources which can be found at http://www.cdc.gov/niosh/npg/.

When respiratory protection is required, a complete respiratory protection program is required in accordance with OSHA’s Respiratory Protection Standard (29 CFR Section 1910.134) which is can be found at http://www.osha.gov/SLTC/respiratoryprotection/index.html. Elements of a respiratory protection program include training, fit testing, medical clearance, change-out schedule, and respirator cleaning, maintenance, and inspection procedures.

E. Voluntary Use of Respirators

Even when comprehensive and routine air monitoring indicates that no inhalational hazard exists, an employer may permit respiratory protection to be worn voluntarily by employees provided it will not in itself create a hazard. See the OSHA Respiratory Protection Standard (29 CFR Section 1910.134).31 The Interim Guidance makes clear those exposure situations where the use of respiratory protection is recommended (see Section IX.C.1. through 5.).

The only situation where voluntary use may be helpful is when an individual is bothered by non-hazardous levels of hydrocarbon odor and cannot be relocated to another work area. In that case, a carbon-impregnated odor-reduction filtering facepiece respirator may provide some odor reduction potential—and can be worn voluntarily without the employer having to implement a respiratory protection program. These types of respirators do not provide health protective effects; they only provide odor reduction. In addition, all respirators have adverse effects on breathing, vision and communication, result in some discomfort, and are associated with additional physiological stress. 32

Employers or volunteer organizations who supply respirators for voluntary use must provide response workers with the information in Appendix D (Information for Employees Using Respirators When Not Required by the Standard) of the OSHA Respiratory Protection Standard, 29 CFR Section 1910.134.33

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